Not because the systems were down, but because user management was broken—scattered permissions, unclear roles, dormant accounts with full access. Every control on paper looked right. In reality, it was chaos. The FFIEC guidelines make one thing clear: this cannot happen.
FFIEC guidelines on user management are not suggestions. They define how regulated institutions must control, track, and review access to systems and data. The stakes are high: breaches, failed audits, and compliance penalties. To align with these guidelines, you need to design user management around three core principles: least privilege, clear accountability, and continuous review.
Least Privilege means no user has more access than their role demands. In implementation, this requires clear definitions for every role—mapped, documented, and reviewed. When role creep happens, privilege audits must catch it.
Clear Accountability means every user action must be tied to a traceable identity. Shared logins destroy audit trails. Multi-factor authentication, unique identifiers, and standardized provisioning workflows are non-negotiable.